TWW Yacht Management Ltd. Candidate and Crew Privacy and Agreement Notice
This notice sets out the basis on which any personal data We collect, or that You provide to Us, will be processed by Us. Your rights under GDPR and Our agreement with You (the Candidate) are set out in this notice.
Glossary of Terms
TWW Yacht Management, Crew Recruitment = Company / Us / We / Our / TWW
Candidate = You / Your / Crew
Client = Stakeholder engaging the services of TWW Yacht Management LTD. / Employer / They
SEA = Seafarers Employment Agreement / Contract
ICO = Information Commissioner’s Office
ILO = International Labour Organisation
MLC = Maritime Labour Convention (MLC 2006)
DPO = Data Protection Officer
Company Contact details
Address: TWW Yacht Management Ltd.,
Office 16, Burnt House Farm Business Park,
Bedlam Lane,
Smarden,
Ashford,
Kent,
TN27 8PG,
GB
Telephone: +44 1223 751 382
Email: yacht-jobs@twwym.com
Company DPO: Glen Campbell
Our Policy / Declaration
TWW Yacht Management Crew Recruitment:
- Always operate without discrimination through all processes.
- Never engage or engineer the use of a ‘Blacklist’ of any kind.
- Never charge any candidate or crew a fee of any kind for registration or recruitment (any and all fees incurred regarding recruitment are the sole responsibility of the Employer).
Candidate Declaration
You the Candidate:
- Will ensure all information provided to TWW and uploaded to this website is accurate and honest. This includes your CV.
- Declare that all qualifications and, or references provided to TWW and uploaded to this website are your property, have not been adjusted or falsified in any way and the information is accurate and correct.
- Agree to us processing and utilising the information and documentation you have provided and that we have collected in order for us to represent you to Clients, with the express purpose of securing Your employment.
Your Rights as a Seafarer
Under the MLC 2006 Legislation, You as a seafarer are entitled to Seafarer Rights, including Conditions of employment, Employment contracts, Wages, Hours of rest, Repatriation, Accommodation & recreational facilities, Medical care and Health & safety protection. This applies to all vessels which are MLC 2006 Compliant.
Complete and detailed information on your Seafarers' rights can be found here
https://www.gov.uk/seafarer-working-and-living-rights/maritime-labour-convention
Upon Employment/ Joining a Vessel
You the seafarer are:
- Required to take original copies, of all Your documentation, on board with You for the vessel records/ inspections.
- Required to supply TWW with a copy of Your signed SEA.
Where this contradicts vessel policy, written confirmation will be required. Including confirmation that You have received, read, signed and obtained a copy of your SEA, as well as confirming You are content that all elements within the SEA are correct.
Privacy and GDPR Policy
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is the regulation which replaces the Data Protection Regulation (Directive 95/46/EC). The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
By using this website, You are indicating that you agree with the terms and conditions in this notice. These may be changed at any time without notice.
What Information We Collect, Use, and Why
To carry out Our core recruitment activities, We collect information about You which may include: Your name, address and postcode; private and corporate e-mail address and phone number; financial information and compliance documentation; references verifying Your qualifications and experience and Your right to work in the United Kingdom; curriculum vitae and photograph; employment details and preferences; links to Your professional profiles available in the public domain e.g. LinkedIn, Twitter, Facebook for Business or corporate website.
We collect or use the following information to comply with legal requirements:
- Name
- Contact information
- Identification documents
- Criminal offence data (including Disclosure Barring Service (DBS), Access NI or Disclosure Scotland checks)
- Health and safety information
- Maritime qualifications
We collect or use the following information for recruitment and crewing purposes:
- Contact details (e.g. name, address, telephone number or personal email address)
- Date of birth
- Copies of passports or other photo ID
- Employment history (e.g. job application, employment references or secondary employment)
- Education history (e.g. maritime or other qualifications)
- Right to work information
- Details of any criminal convictions (e.g. Disclosure Barring Service (DBS), Access NI or Disclosure Scotland checks)
- Job preferences (e.g. role, leave type, desired salary, vessel location or itinerary, etc.)
We collect or use the following personal information for dealing with queries, complaints or claims:
- Names and contact details
- Address
- Video recordings of public areas or available on public forums
- Audio recordings of public areas or available on public forums
- Call recordings
- Witness statements and contact details
- Relevant information from previous investigations
- Correspondence
Lawful Bases and Data Protection Rights
Under UK data protection law, We must have a “lawful basis” for collecting and using Your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis We rely on may affect Your data protection rights which are in brief set out below. You can find out more about Your data protection rights and the exemptions which may apply on the ICO’s website:
- Your right of access - You have the right to ask Us for copies of Your personal information. You can request other information such as details about where We get personal information from and who We share personal information with. There are some exemptions which means You may not receive all the information You ask for.
- Your right to rectification - You have the right to ask Us to correct or delete personal information You think is inaccurate or incomplete.
- Your right to erasure - You have the right to ask Us to delete Your personal information.
- Your right to restriction of processing - You have the right to ask Us to limit how We can use Your personal information.
- Your right to object to processing - You have the right to object to the processing of Your personal data.
- Your right to data portability - You have the right to ask that We transfer the personal information You gave us to another organisation, or to You.
- Your right to withdraw consent – When We use consent as our lawful basis You have the right to withdraw Your consent at any time.
Making a Data Protection Rights Request:
- Please contact Us, in writing, using the contact details at the top of this privacy notice. Emails contain GDPR Rights Request in the subject line.
- We must respond to You without undue delay and in any event within one month.
- We will acknowledge Your request and inform You of the action being taken.
Our Lawful Bases For The Collection and Use of Your Data
Our lawful bases for collecting or using personal information for legal requirements are:
- Consent - We have permission from You after we gave You all the relevant information. All of Your data protection rights may apply, except the right to object. To be clear, You do have the right to withdraw Your consent at any time.
- Contract – We have to collect or use the information so We can enter into or carry out a contract with You. All of Your data protection rights may apply except the right to object.
- Legal obligation – We have to collect or use Your information so We can comply with the law. All of Your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Vital interests – collecting or using the information is needed when someone’s physical or mental health or well-being is at urgent or serious risk. This includes an urgent need for life-sustaining food, water, clothing or shelter. All of Your data protection rights may apply, except the right to object and the right to portability.
- Public task – We have to collect or use Your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as OOurs. All of Your data protection rights may apply, except the right to erasure and the right to portability.
Our lawful bases for collecting or using personal information for recruitment and crewing purposes are:
- Consent - We have permission from You after We gave You all the relevant information. All of Your data protection rights may apply, except the right to object. To be clear, You do have the right to withdraw Your consent at any time.
- Contract – We have to collect or use the information so We can enter into or carry out a contract with You. All of Your data protection rights may apply except the right to object.
- Legal obligation – We have to collect or use Your information so We can comply with the law. All of Your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Vital interests – collecting or using the information is needed when someone’s physical or mental health or well-being is at urgent or serious risk. This includes an urgent need for life-sustaining food, water, clothing or shelter. All of Your data protection rights may apply, except the right to object and the right to portability.
- Public task – We have to collect or use Your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as Ours. All of your data protection rights may apply, except the right to erasure and the right to portability.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
- Consent - We have permission from You after we gave You all the relevant information. All of Your data protection rights may apply, except the right to object. To be clear, You do have the right to withdraw Your consent at any time.
- Contract – We have to collect or use the information so We can enter into or carry out a contract with You. All of Your data protection rights may apply except the right to object.
- Legal obligation – We have to collect or use Your information so We can comply with the law. All of Your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Vital interests – collecting or using the information is needed when someone’s physical or mental health or well-being is at urgent or serious risk. This includes an urgent need for life-sustaining food, water, clothing or shelter. All of Your data protection rights may apply, except the right to object and the right to portability.
- Public task – We have to collect or use Your information to carry out a task laid down in law, which the law intends to be performed by an organisation such as Ours. All of Your data protection rights may apply, except the right to erasure and the right to portability.
Where We Get Personal Information From
- Directly from You
- Legal and judicial sector organisations
- Publicly available sources
- Previous employers, referees and colleagues
- Suppliers and service providers
Where We Store Your Personal Data
All information stored on Our recruitment and crewing software is secured through the Microsoft Azure Infrastructure and located at two data centre locations within Europe. Our primary centre is located in Microsoft’s Western European centre, and these facilities are secured by a series of measures, including (but not limited to) biometric access, security alarm systems and round-the-clock security staff. Additional security information on Microsoft’s data centres can be found here.
How Long We Keep Information
We retain different types of data for differing periods of time.
The criteria We use to determine whether We should retain Your personal data and for how long include:
- The nature of the personal data.
- The perceived accuracy of Your data.
- Your engagement levels with Our services.
- Our legal obligations following an offer or when a placement has been made.
We may archive part or all of Your personal data, or retain it on our financial systems but delete all or part of it from Our recruitment software system. On removal, We may anonymise parts of Your data – particularly following a request for suppression or deletion of Your data – to ensure We do not re-enter Your personal data into Our database, unless You have requested us to do so.
Our current retention period for data on candidates who have not been placed by Us or are no longer showing any signs of engagement with Our website is 5 Years.
We will retain candidate's data, who are engaged with Our website or have been placed by Us, until the candidate requests deletion or when it is no longer necessary for the company to hold that personal data with respect to the purpose for which it was originally collected or processed.
Who We Share Information With
Others We share personal information with
- Insurance companies
- Organisations we need to share information with for safeguarding reasons
- Vessel ownership, vessel management, vessel employers or bare-boat charter companies
- Professional or legal advisors
- Relevant regulatory authorities
- External auditors or inspectors
- Professional consultants
- Key stakeholder in the recruitment and employment process
- Organisations we’re legally obliged to share personal information with
Sharing Information Outside the UK
Your CV and relevant details will be shared with Our Clients as potential employers. After securing a placement, further information and documentation will be provided to facilitate the employment process and Our legal responsibilities under this. These parties can be based within the European Economic Area (EEA); however, they may also be located outside of it.
For further information please contact Us using the contact information provided above.
Changes to our privacy notice
Any changes We make to Our privacy notice in future will be posted on this page and, where appropriate, You may be notified by e-mail. Please check back frequently to view any updates or changes to Our privacy notice.
For any further information please email: yacht-jobs@twwym.com
How To Complain
If You have any concerns about Our use of your personal data or Your general experience with Us, you can make a complaint to Us using the contact details at the top of this privacy notice.
Including via email: yacht-jobs@twwym.com
We must respond to You without undue delay and in any event within one month.
We will acknowledge Your request and inform You of the action being taken
If You remain unhappy with how We’ve used Your data after raising a complaint with Us, You can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint
This Document Was Last updated: 29th January 2025